Employees' Compensation appeal is limited to substantial questions of law and cannot re-examine unproven factual defenses.

The respondents (legal heirs of Sh. Sanoj Kumar) filed a claim application alleging that the deceased suffered fatal electrocution on 08.04.2022 while performing flooring work at the appellant’s premises

The appellant filed a written statement denying the employer-employee relationship, asserting that the work was contracted to one Shyam Kumar via an agreement dated 06.04.2022

The appellant subsequently abandoned the proceedings and was proceeded against ex parte

The Commissioner awarded compensation of Rs.15,88,425/- plus interest and funeral expenses

The appellant’s review application was dismissed after he again failed to appear

1. Whether a substantial question of law exists under Section 30 of the Employees’ Compensation Act, 1923 to warrant interference with the Commissioner's factual findings

2. Whether the appellant proved the existence of an independent contractor agreement to absolve himself of liability as an employer

3. Whether discrepancies in the timing of the incident between the FIR and the claim application vitiate the respondents' case

Section 30 of the Employees’ Compensation Act (EC Act), 1923, which restricts the scope of appeals to "substantial questions of law" and establishes the Commissioner as the final authority on facts

The precedent Golla Rajanna & Ors. v. Divisional Manager & Anr., which clarifies that the EC Act is welfare legislation intended to protect workmen

Principles of the Indian Evidence Act regarding the burden of proof, noting that a document (like the unregistered agreement) must be proved in accordance with law to be considered as evidence

The court observed that the appellant failed to produce the alleged agreement with Shyam Kumar during the evidence stage and did not cite him as a witness

The document remained "unproved" as it was an unregistered paper and the appellant’s repeated absence led to ex parte proceedings

Regarding the employer-employee relationship, the court found no reason to disturb the Commissioner’s findings because the work was admittedly performed at the appellant's premises for his benefit

Addressing the discrepancy in timing (6:00 p.m. vs 11:00 p.m.), the court held it was immaterial as the date, location, and occurrence of the fatal accident were not in dispute

The court emphasized that since the appellant could not demonstrate any perversity in the factual findings, no substantial question of law arose under Section 30

The High Court dismissed the appeal. The award of Rs.15,88,425/- with 12% interest remains upheld. All pending applications were disposed of